Case No. SDGT-855; 2007 Letter From OFAC re: Blocked Property Reporting Requirements

Date issued: Dec. 26 2007

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TURBOFAC Commentary (495 words)

Notes:

1) This letter, as with others related to the Kindhearts case, takes the position that seized "records" of a blocked person are "property" within the scope of the GTSR (594.309). In general, papers that are not negotiable instruments are not "property" that is treated as subject to reporting requirements of the RPPR. It is not clear what standard OFAC used to assert jurisdiction over Kindhearts' "records" as "property" in this case. Compare Case Nos. SDGT-572 and SDGT-574; License No. SDGT-572 (Kindhearts' lawyer had access to Kindhearts' incoming mail, was directed to move any incoming funds to a blocked account, but no suggestion that other mail was blocked "property"). Here, OFAC says that "KindHearts documents held...